IR 05000289/1989005
| ML20245D936 | |
| Person / Time | |
|---|---|
| Site: | Crane, Fort Calhoun  |
| Issue date: | 04/18/1989 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Morris K OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8905010237 | |
| Download: ML20245D936 (2) | |
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p In Reply l Refer To:
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. Docket: 50-285/89-05
.0maha Public' Power' District ATTN:: Kenneth J. Morris.; Division Manager Nuclear 10perations 1623 Harney Street-Omaha, Nebraska' 68102 r
Gentlemeni
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iThank you for your letter of April 3; 1989,Lin response to our letter and the j
attached Notice of Violation dated: March 3.11989. L As-a result of our review.
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we: find that additional information, as discussed with your Mr. J; Fisicaro on
~j-April'12, 1989..is needed.. Specifically, more. definitive detail is required in
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.the correctiveisteps.you are taking to avoid further violations.
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-Please provide the supplemental information within 30 days of the
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Sincerely, Original 6 L.1.Ca b L. J. Callan, Director Division of Reactor Projects.
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Fort-Calhoun Station ATTN:.. G. Gates, Manager W
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P.O. Box 399 Fort Calhoun, Nebraska. 68023-Harry H. Voigt. Esq.
LeBoeuf, tainb, Leiby & MacRae
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1333 Ns( Hampshire Avenue, NW Washington, DC 20036
. Nebraska Radiation Control Program Director
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Omaha Public Power District 1623 Harney Omaha. Nebraska 68102 2247 -
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April 3, 1989
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LIC-89-329 APR - 51989 ]h l
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idj U. S. Nuclear Regulatory Commission
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Attn: Document Control Desk L_.
Mail Station P1-137 Washington, DC 20555 References:
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Docket No. 50-285 2.
Letter from NRC (L. J. Callan) to OPPD (K. J. Morris) dated March 3, 1989 Gentlemen:
SUBJECT:
Response to Notice of Violation NRC Inspection Report 50-285/89-05 Omaha Public Power District (OPPD) received the Notice of Violation dated March 3, 1989. The violation involved inadequate design control measures concerning the verification and checking of a design calculation regarding Pipe Support SIS-8 on the safety injection system.
The calculation for Pipe Support SIS-8 included the use of an incorrect dimension.
The error was not discovered during the independent review process.
A review of drawings for CQE pipe supports modified as part of the NRC Bulletin No. 79-14 upgrade program has disclosed that eight additional supports are similar in design to SIS-8.
The calculations for these nine pipe supports SIS-8; -20; -38; -45; -45A; -46; -49; -71A; -97 were reviewed for overall adequacy and to determine if similar errors existed.
No additional errors were found in the calculations. As a result of another unrelated effort, six of these nine pipe supports have had calculations performed by a different engineering firm confirming the adequacy of design.
The error in Pipe Support SIS-8 calculation FC02923 was evaluated and it was determined that the loads are still within allowable limits when the correct dimension is used.
It has been concluded that the error in Pipe Support SIS-8 calculation FC02923 is an isolated incident based on the oversight of the preparer and the reviewer to select the correct dimension for the moment arm, and is not due to inadequate design control measures.
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' Pursuant to the provisions of 10 CFR Part 2.201, please find attached,.OPPD's response to~the violation.-
If.you have any questions concerning this matter, t
please.do not-hesitate to contact us.
Sincerely,
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Nuclear Operation ~s'
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Attachment c:
LeBoeuf, Lamb, Leiby & MacRae
"R?ID D Marti dis NRCTRegion al:Admi ni s tratori P. D. Milano, NRC Project Manager.
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P. H. Harrell, NRC Senior Resident Inspector.
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Attachment
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.c RESPONSE TO NOTICE OF VIOLATION During an NRC inspection conducted January 30 through February 3, 1989, a
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violation of NRC requirements was identified. The violation involved inadequate design control, including the verification and checking of design calculations regarding a pipe support on the safety injection system.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violation is listed below:
Criterion III of Appendix B to 10 CFR Part 50 and the licensee's approved quality assurance program description requires that design control measures shall provide for verifying or checking the adequacy of design, such as the performance of design reviews, by the use of alternate or simplified calculations.
Contrary to the above, a design discrepancy involving the use of an incorrect dimension in Calculation FC02923 regarding the maximum moment for Pipe Support SIS-8, was not identified due to the inadequate design control measures.
This is a Severity Level IV violation.
(Supplement I)(285/8905-01)
OPPD RESPONSE 1.
Admission or Denial of the Alleaed Violation OPPD admits that an incorrect dimension was used in Pipe Support SIS-8 calculation FC02923, but belives that the incident was an isolated personnel error.
The pertinent design control measures governing the preparation, checking, and verification of the calculations were adequate for the reasons described below.
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The Reasons For the Violation. If Admitted Calculation FC02923 was performed to justify the redesign of Pipe Support SIS-8.
The redesign of the pipe support resulted from a design review conducted in response to NRC Bulletin No. 79-14. An engineering firm was contracted to perform this work.
The dimensions used in the calculation were extracted from the several dimensions available on the pipe support design drawing and in vendor literature.
The use of the incorrect dimension for the moment arm resulted from an error by the calculation preparer and the oversight by the reviewer in selecting the correct dimension.
The selection of the incorrect dimension is believed to be an isolated incident since a review of similar pipe support calculations by the same individuals revealed no other errors.
Adequate design control measures for performing calculations, checking and verifying design were in place.
The calculations were performed under the Quality Assurance Program of the engineering firm and in accordance with their design control procedures for Design Input, Calculations and Design Verification.
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'In ' June,1981, OPPD conducted Quality Assurance Audit No. 21-81 of the engineering firm's QA program and procedures associated with the NRC
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Bulletin No. 79-14 related work.
This audit which found the design control measures acceptable also reviewed twelve pipe support calculation packages.
The acceptability of the design control procedures as confirmed by the OPPD audit, combined with the design verification forms completed for each of the pipe support calculations demonstrate that adequate design control measures were in place.
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The Corrective Steps That Have Been Taken and the Results Achieved The error in calculation FC02923 was evaluated and it was found that the loads are still within allowable limits when the correct moment arm dimension is used.
A review of drawings for CQE pipe supports modified during the NRC Bulletin No. 79-14 upgrade program has disclosed that eight additional supports are similar in design to SIS d.
The calculations for these nine pipe supports
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SIS-8, -20, -38, -45, -45A, -46, -49, -71A, and -97,were reviewed for overall adequacy and to ' determine if similar " incorrect dimension" errors existed.
No additional errors were found in these calculations.
During this review for adequacy and " incorrect dimension" errors, it was noted that the same individuals who prepared and reviewed the SIS-8 pipe support calculation were also involved with the calculations for the eight other similar pipe supports.
There were no incorrect dimensions used in these calculations.
This further supports our belief that the use of an incorrect dimension in the Pipe Support SIS-8 calculation was an isolated incident.
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Corrective Steos Which Will Be Taken To Avoid Further Violations OPPD will continue to promote attention to detail and emphasize the importance of design control process and procedures.
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Date When,[ull Comoliance Will Be Achieved OPPD is currently in full compliance.
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